In Re Bright Health Management, Inc. v. the State of Texas

Court of Appeals of Texas·Decided June 20, 2025·No. 15-25-00108-CV·Published

Opinion

ACCEPTED

15-25-00092-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

6/20/2025 5:16 PM

NO. 15-25-00092-CV CHRISTOPHER A. PRINE CLERK

IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT AUSTIN, TEXAS 15th COURT OF APPEALS

AUSTIN, TEXAS 6/20/2025 5:16:15 PM CHRISTOPHER A. PRINE

Clerk

IN RE BRIGHT HEALTH MANAGEMENT, INC., Appellant,

v.

BRIGHT HEALTH INSURANCE COMPANY OF TEXAS, Appellee.

On Appeal from the

455th Judicial District Court, Travis County, Texas Cause No. D-1-GN-23-008361 The Honorable Catherine Mauzy, Presiding

AND

NO. ____________

IN THE COURT OF APPEALS

FOR THE FIFTEENTH JUDICIAL DISTRICT AUSTIN, TEXAS

IN RE BRIGHT HEALTH MANAGEMENT, INC.

Relator.

Original Proceeding Arising from the 455th Judicial District Court, Travis County, Texas

Cause No. D-1-GN-23-008361 The Honorable Catherine Mauzy, Presiding

BRIGHT HEALTH MANAGEMENT, INC.’S EMERGENCY MOTION FOR STAY OF DISTRICT COURT’S ORDER

Carlos Soltero

csoltero@maynardnexsen.com State Bar No. 00791702

Brytne D. Kitchin

bkitchin@maynardnexsen.com State Bar No. 24079973

Lisa Alcantar

lalcantar@maynardnexsen.com State Bar No. 24069284

MAYNARD NEXSEN

2500 Bee Caves Road

Bldg. 1, Suite 150

Austin, Texas 78746

Counsel for Appellant/Relator

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellant/Relator Bright Health Management, Inc. (“BHM”)

respectfully files this Emergency Motion for Stay of District Court’s Order (attached to this Motion as Exhibit 1) pursuant to Texas Rule of Appellate Procedure 29.3 or, in the alternative, 52.10. BHM asks this Court to stay the proceedings in the District Court as outlined below to preserve this Court’s ability to rule on BHM’s interlocutory appeal or, in the alternative, petition for writ of mandamus. BHM filed its Notice of Appeal on May 16, 2025.

INTRODUCTION

On May 6, 2025, the Honorable Catherine Mauzy, presiding in the 455th Judicial District Court, Travis County, signed an Order Granting Special Deputy Receiver’s Motion to Confirm Special Master’s Recommendation and for Entry of Order Granting the Motion to Enforce Permanent Injunction Against Bright Health Management, Inc. (the “Order”), compelling BHM to produce business records it held and maintained on behalf of Bright Health Insurance Company of Texas, Inc. (“BHICOT”), a Texas-domiciled insurance company in receivership, and denying BHM’s Cross-Motion for Entry of Order Governing

Electronically Stored Information (the “ESI Motion”). The appellee/real party in interest is BHICOT.

The Order arose after the Special Deputy Receiver of BHICOT (the “SDR”) demanded that BHM turn over all BHICOT-related emails of BHICOT’s officers and directors and all BHM employees. BHM operates as a shared-services entity, providing management and administrative services to all its insurance company subsidiaries pursuant to separate management services agreements.1 The suite of services offered by BHM includes providing BHM employees to serve as officers and/or directors of an insurance company client as well as “claims administration, accounting, legal services, financial services, actuarial services. Effectively everything.” 2 BHM employees, like the employees of most management companies that are part of a large holding company structure, have a single email address. Thus, simply providing the SDR with all emails of the BHM employees who served as officers and directors of BHICOT or

1 Indeed, prior to commencement of the receivership, BHM and BHICOT entered into

a Management Services Agreement (the “MSA”), under which BHM agreed to manage the day-to-day operations of BHICOT’s Texas-based health insurance business, including maintenance of BHICOT’s books and records. 2 3 RR 762, p. 162:24–163:7.

provided other services to BHICOT would result in the SDR receiving thousands of emails and other documents wholly unrelated to BHICOT.3 Worse, these irrelevant documents and emails contain information about the affiliates to whom BHM also provides management services, including protected health information relating to medical clinics operated by BHM’s affiliate, NeueHealth, Inc., and its subsidiaries (collectively, “NeueHealth”). Further compounding the problem is the inclusion of attorneys among the relevant custodians, whose roles include serving in the capacity of general in-house counsel, providing legal advice to affiliated entities on myriad subjects unrelated to BHICOT.

To maintain the confidentiality of the information in BHM’s possession that is unrelated to BHICOT, BHM proposed coordinating efforts to identify key search terms and queries to address any legitimate interest the SDR, on behalf of BHICOT, may have in the emails. Initially, the SDR agreed to have, “the respective IT professionals work together to agree on key search terms and queries,” and agreed to provide proposed terms and queries. However, the SDR later withdrew this

3 For example, the initial data pull of the BHM employees who served as BHICOT’s

officers and directors produced roughly 600,000 emails, much of which was unrelated to BHICOT.

agreement to collaborate, now stating it, “did not intend to limit BHM’s obligation to produce BHICOT’s business records,” and that, “[t]he search parameters should be all records that mention, refer to or relate to BHICOT.”

Having reached an impasse, the SDR filed a Motion to Enforce Injunction Against BHM to compel production of BHICOT’s business records, and BHM filed the ESI Motion, arguing the SDR has no blanket right to examine all BHM records without regard to whether they are BHICOT records. However, the District Court’s Order effectively requires BHM to do just that, with a status report due to the District Court by May 26, 2025, and every 20 days thereafter, and all documents produced by August 4, 2025. Therefore, BHM seeks immediate protection from the Order to preserve this Court’s ability to rule on BHM’s interlocutory appeal or, in the alternative, petition for writ of mandamus (the “Appeal”).

ARGUMENT

Pursuant to Texas Rule of Appellate Procedure 29.3 or, in the alternative, 52.10, this Court has the authority to grant a stay to preserve an appellant’s or relator’s rights, respectively, until disposition of an

appeal or writ of petition for mandamus. TEX. R. APP. P. 29.3 & 52.10(b). Here, an immediate stay of the Order is necessary to preserve BHM’s rights pending disposition of its Appeal.

The Order effectively requires BHM to provide the SDR with confidential and potentially highly sensitive NeueHealth information that is wholly unrelated to BHICOT, including privileged and HIPAA- protected materials, and to which the SDR is not entitled to under the MSA or any law. BHM understands that the SDR’s request is not exactly a traditional “discovery request,” as it relates to seeking the books and records of an insurance company in receivership. But, absent any statutory requirements or other applicable guidelines for production of documents in an insurance company receivership, BHM contends that Texas’ well-established ESI principles cannot be simply ignored. Even if the ESI jurisprudence of In re Weekly Homes and other authorities may not be completely controlling legal precedent, they are not irrelevant to this legal inquiry and at a minimum are highly instructive. This is particularly true here, where in the absence of the MSA, the SDR would be required to follow the Texas Rules of Civil Procedure that govern the

production of documents from non-parties, even in connection with enforcing a court-issued injunction.

Free access — add to your briefcase to read the full text and ask questions with AI

In Re Bright Health Management, Inc. v. the State of Texas, (Tex. Ct. App. 2025).

In Re Bright Health Management, Inc. v. the State of Texas (In Re Bright Health Management, Inc. v. the State of Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

In Re Weekley Homes, L.P.
295 S.W.3d 309 (Texas Supreme Court, 2009)
Russell v. Young
452 S.W.2d 434 (Texas Supreme Court, 1970)
in Re Ford Motor Company and Ken Stoepel Ford, Inc.
427 S.W.3d 396 (Texas Supreme Court, 2014)
in Re State Farm Lloyds
520 S.W.3d 595 (Texas Supreme Court, 2017)
In re Shipman
540 S.W.3d 562 (Texas Supreme Court, 2018)